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Background
On June 8, 2005, respondent issued to petitioner a Decision
Letter Concerning Equivalent Hearing Under Section 6330 of the
Internal Revenue Code2 (decision letter) regarding his unpaid
Federal income tax liabilities for 1998 and 2000, in which
respondent’s Office of Appeals sustained the levy action.3 On
July 6, 2005, petitioner sent to the Court a document, which
states in relevant part:
Dear Tax Court Judge,
The Collection Due Process (hereafter “CDP”) Hearing
that I requested has been decided. I need your
assistance regarding a Notice of Levy I received from
the Internal Revenue Service (hereafter “IRS”) for the
tax years 1998 and 2000. I believe that this hearing
process has been unfair and biased. The IRS appeals
agent refused to grant me a CDP Hearing, which I
requested on 12/07/04. Instead, she attempted to give
me an Equivalent Hearing. Nor did the appeals agent
provided [sic] the information I requested.
I am filing a petition with the U.S. Tax Court because
I believe the IRS numbers are wrong and they have
violated their own procedures. I think the IRS is
wrong but I am not sure if I am doing this protest
right. I told the IRS I didn’t owe them anything and
they still have not shown me any proof to support their
claim. Could you please write to me and let me know
the procedure?
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
3 While the basis of petitioner’s claim is not entirely
clear, we note that it is doubtful that a decision letter
concerning an equivalent hearing could be appealed to this Court.
See Offiler v. Commissioner, 114 T.C. 492, 498 (2000).
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Last modified: May 25, 2011